DCT

2:25-cv-00900

Ecovacs Robotics Co Ltd v. Bejing Roborock Technology Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00900, E.D. Tex., 09/10/2025
  • Venue Allegations: Venue is alleged to be proper on the basis that Defendants are foreign entities, which may be sued in any judicial district pursuant to 28 U.S.C. § 1391(c)(3).
  • Core Dispute: Plaintiff alleges that Defendant’s robotic vacuums infringe a patent related to the method a robot uses to determine and execute a new task after being manually moved by a user to a different location.
  • Technical Context: The technology at issue involves autonomous navigation and adaptive task management logic for mobile robots, a critical area of innovation in the competitive consumer market for robotic vacuum cleaners.
  • Key Procedural History: The filing is a First Amended Complaint. The complaint does not mention other significant procedural events such as prior litigation or administrative challenges to the patent-in-suit.

Case Timeline

Date Event
2018-07-19 '753 Patent Priority Date
2023-12-26 '753 Patent Issue Date
2025-09-10 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,850,753 - "Robot Control Method, Robot and Storage Medium"

  • Patent Identification: U.S. Patent No. 11,850,753, titled "Robot Control Method, Robot and Storage Medium," issued on December 26, 2023 (’753 Patent, cover; Compl. ¶30).

The Invention Explained

  • Problem Addressed: The patent describes a problem in existing robot technology where an autonomous robot, after being manually moved or "hijacked" by a user, would experience localization errors. Upon re-establishing its position, the robot would typically return to the location where it was hijacked to resume its previous task. This approach is described as inflexible and potentially contrary to the user's intent. (’753 Patent, col. 1:17-29; Compl. ¶¶33-34).
  • The Patented Solution: The invention proposes a method where the robot, after being moved and re-localizing, determines a new "task execution area" based on the environmental information of its new location. It then executes a task within this new area instead of returning to the original point of interruption. This allows the robot to "flexibly determine the task execution area according to the environment" and "act according to local conditions." (’753 Patent, Abstract; col. 3:7-18; Compl. ¶35).
  • Technical Importance: This technology represents a method for making autonomous robots more adaptive to user intervention, shifting from rigid task continuation to context-aware task initiation. (’753 Patent, col. 3:15-18).

Key Claims at a Glance

  • The complaint specifically alleges infringement of claim 16, an independent method claim. (Compl. ¶42).
  • The essential elements of independent claim 16 are:
    • Determining, by a robot, its position when it is released from being hijacked, based on a relocalization operation.
    • Determining, by the robot, a task execution area according to environmental information around its new position.
    • Executing, by the robot, a task within that task execution area.
    • A further condition that the determination of the new task execution area occurs if the robot's release position and hijack position belong to "different environmental areas." (’753 Patent, col. 27:15-42).
  • The complaint alleges infringement of "one or more claims," suggesting the possibility that other claims, including dependent claims, may be asserted later. (Compl. ¶38).

III. The Accused Instrumentality

Product Identification

  • The Roborock S8 MaxV Ultra and "all reasonably similar products" are identified as the Accused Products. (Compl. ¶1).

Functionality and Market Context

  • The complaint alleges the Accused Products are robotic vacuums that contain "artificial intelligence and other internal control methods that allow the robot to navigate and clean a home." (Compl. ¶43). Specific technologies mentioned include "Reactive AI 2.0 Obstacle Recognition" and "PreciSense® LiDAR Navigation." (Compl. p. 15). A visual from Defendant's website, included in the complaint, describes the LiDAR navigation as the "brain of the robot vacuum, creating detailed maps of the home, identifying the optimal cleaning routes, and powering a suite of useful app features." (Compl. p. 15). The complaint alleges these products are sold in the United States through major retailers and Defendant's own website. (Compl. ¶¶14-19).

IV. Analysis of Infringement Allegations

'753 Patent Infringement Allegations

Claim Element (from Independent Claim 16) Alleged Infringing Functionality Complaint Citation Patent Citation
determining, by a robot, a position when the robot is released from being hijacked based on relocalization operation; The S8 MaxV Ultra uses AI and LiDAR navigation to determine its position within a home. ¶¶43, 44 col. 3:23-26
determining, by the robot, a task execution area according to environmental information around the position when the robot is released from being hijacked; The S8 MaxV Ultra "analyzes surrounding environmental information where it is released." ¶44 col. 3:27-30
and executing, by the robot, a task within the task execution area; The S8 MaxV Ultra "will clean the room in which it was released." ¶45 col. 3:31-33
wherein the determining... comprises: if the position when the robot is released from being hijacked and the position when the robot is hijacked belong to different environmental areas, determining the task execution area at the position when the robot is released from being hijacked. "When the release position is in a different room than the hijack position, the S8 MaxV Ultra will clean the room in which it was released." ¶45 col. 7:41-51

Identified Points of Contention

  • Scope Questions: A potential point of contention may be the meaning of "environmental area." The infringement theory appears to equate this term with a "room." The analysis will question whether the accused product's internal mapping and logic technically distinguish between "environmental areas" in a manner consistent with the patent's teachings, or if its behavior is the result of a different operational logic.
  • Technical Questions: The complaint alleges that the accused product "analyzes surrounding environmental information" to perform the claimed method. A key technical question will be what specific data the product collects and processes upon being moved, and whether that process constitutes "determining a task execution area" as required by the claim, versus simply initiating a default cleaning cycle in a newly discovered space.

V. Key Claim Terms for Construction

The Term: "environmental area"

  • Context and Importance: This term is critical to the infringement analysis, as the core limitation of asserted claim 16 is triggered only when the robot is moved between "different environmental areas." The definition of this term will determine the factual circumstances under which infringement could occur.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that "Depending on the application scenarios, the division and definition of the environmental areas may vary," which may support a flexible definition not strictly limited to physical rooms. (’753 Patent, col. 7:31-33).
    • Evidence for a Narrower Interpretation: The specification provides concrete examples of what "may be considered as relatively independent environmental areas," listing "bedrooms, kitchens, living rooms, toilets, etc." (’753 Patent, col. 7:34-37). This language may be used to argue that the term is limited to functionally distinct architectural spaces.

The Term: "hijacked"

  • Context and Importance: This term defines the event that initiates the claimed method. Its construction will clarify what kind of user interaction falls within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent provides a broad definition, stating that behaviors like being "moved, suspended or dragged by a wide range and the like are uniformly defined as that the robot is hijacked." (’753 Patent, col. 4:33-37).
    • Evidence for a Narrower Interpretation: The problem statement in the background focuses on "uncontrollable drift errors" that occur when the robot is moved. (’753 Patent, col. 1:22-23). This context could support an argument that "hijacked" implies a disruptive manual movement that causes the robot to lose its localization, rather than any simple, intentional relocation by the user.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges induced infringement, stating that Defendant provides "documentation, support services, and marketing materials" that instruct and encourage customers to use the Accused Products in a manner that performs the steps of the claimed method. (Compl. ¶¶39, 47).

Willful Infringement

  • Willfulness is alleged based on Defendant having knowledge of the ’753 patent "at least since the filing of the Complaint in this litigation." (Compl. ¶40). This allegation appears directed at post-suit conduct.

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of definitional scope: can the term "environmental area," which the patent illustrates with examples like "bedrooms" and "kitchens," be construed to cover how the accused robotic vacuum's software algorithmically defines and distinguishes between different mapped sections of a home?
  • A key evidentiary question will be one of causation and operational logic: does the accused product perform a new cleaning task in a new room because it has executed the specific, multi-step decision-making process recited in Claim 16, or does it do so as a result of a more general-purpose logic, such as initiating a default cleaning routine whenever it finds itself in an area it does not recognize as part of a prior, uncompleted task?